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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON DC 20549

DIVISION OF CORPORATION FINANCE

January 28 2014

Susan A W axenberg Time Warner Cable Inc susanwaxenbergtwcablecom

Re Time Warner Cable Inc

Dear Ms Waxenberg

This is in regard to your letter dated January 22 2014 concerning the shareholder proposal submitted by the Unitarian Universalist Service Committee and the Needmor Fund for inclusion in Time Warners proxy materials for its upcoming annual meeting of security holders Your letter indicates that the proponents have withdrawn the proposal and that Time Warner therefore withdraws its January 102014 request for a no-action letter from the Division Because the matter is now moot we will have no further comment

Copies ofall ofthe correspondence related to this matter will be made available on our website at httpwwwsecgovdivisionscorpfincf-noaction14a-8shtml For your reference a briefdiscussion ofthe Divisions informal procedures regarding shareholder proposals is also available at the same website address

Sincerely

Raymond A Be Special Counsel

cc Constance Kane Unitarian Universalist Service Committee 689 Massachusetts A venue Cambridge MA 02139-3302

The Needmor Fund co Daniel Stranahan 2123 West Webster A venue Chicago IL 6064 7

Time Warner Cable

BY OVERNIGHT COURIER

Office of Chief Counsel Division of Corporation Finance Securities and Exchange Commission 100 F Street N E Washington DC 20549

January 222014

Ladies and Gentlemen

Re Time Warner Cable Inc- Shareholder Proposal of the Unitarian Universalist Service Committee and The Needmor Fund-shyWithdrawal of Request

In a letter dated January 10 2014 on behalf ofTime Warner Cable Inc (the Company) I requested that the Staff of the Division of Corporation Finance concur that the Company could properly exclude from its proxy statement and proxy to be filed and distributed in connection with its 2014 annual meeting ofstockholders (collectively the 2014 Proxy Materials) a proposal (the Proposal) and supporting statement submitted to the Company on August 6 2013 by the Unitarian Universalist Service Committee and The Needmor Fund as coshyfilers (the Proponents~)

Attached as Exhibit A and Exhibit B respectively is a letter dated January 17 2014 from each Proponent to the Company stating that each Proponent voluntarily withdraws the Proposal In reliance on this letter we hereby withdraw the January 102014 no-action request relating to the Companys ability to exclude the Proposal from its 2014 Proxy Materials pursuant to Rule 14a-8 under the Securities Exchange Act of 1934

Please acknowledge receipt of this letter by signing the enclosed copy ofthis letter and returning it in the postage paid envelope provided middot

Please do not hesitate to call me at (212) 364-8519 or by fax at (704) 973-6245 if I may be of further assistance in this matter

Sincerely

fwcuL A lJ~~ Susan A Waxenberg [I Vice President amp Chief Counsel Securities

Enclosures

60 Colun1bus Circle

New York NY 10023

cc Constance Kane The Unitarian Universalist Service Committee Daniel Stranahan The Needmor Fund Timothy Smith Walden Asset Management Mary E Alcock Cleary Gottlieb Steen amp Hamilton LLP

Exhibit A

Letter from The Needmor Fund

THE NEEDMOR FUND

January 17 2014

Mr Marc Lawrence-Appelbaum Corporate Secretary Time Warner Cable Inc 60 Columbus Circle 17th floor New York NY 10023

Dear Mr Lawrence-Appelbaum

This letter confirms that the Needmor Fund is withdrawing its shareholder resolution requesting review of lobbying related to climate change

14~~~1 Daniel Stranahan ~AChair- Finance Committee _ -f Encl Resolution Text

CC~ Timothy Smith Walden Asset Management One Beacon St aoston MA 02108

The Needmor Fund co Daniel Stranahan

2123 West Webster Avenue Chicago IL 60647

ExhibitB

Letter from Unitarian Universalist Service Committee

middot

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middotJanuary 17 2013

Mr Marc Lawrance-Appelbaum Corporate Secretary Time Warner Cable Inc 60 Columbus Circle 17th floor New York NY 10023

Dear Mr La~ence-Appelbaum

This letter confirms that the Unitarian Universalist Servi~ Committee is withdrawing its shareholder resolution requesting for a review of lobbying related to climate change

Sincerely~

~~~~sOfficer ~ Enclosure Resolution

Cc Timothy Smith -Walden Asset Manag~~pnt

UNITARIAN UNIVERSAUST SERVICE COMMITTEE 689 Massachusetts Avenue Cambridge MA 02139-3302617-868-6600 fax 617-868-7102

wwwuuscorg

Walden Asset Management Jtfvtmcing sustaina6(e 6usiness pr-actices since 19 75

January 17 2014

Ms Susan A Waxenberg Vice President amp Chief Counsel Securities Time Warner Cable Inc 60 Columbus Circle 1ih floor New York NY 1 0023

Dear Ms Waxenberg

I write in response to your January 1 0 2014 letter to the Securities and Exchange Commission (SEC) This letter chall~nged the shareholder resolution led by the Needmor Fund and Unitarian Universalist Service Committee (Walden clients)

This extensive and thoughtful letter raises two major arguments against the resolution the first of which is that it substantially conflicts with a shareholder resolution on lotgtbying Having studied the two resolutions and the No Action Letter we agree there is meaningful overlap

Thus the Needmor Fund and Unitarian Universalist Service Committee are withdrawing the resolution in question A letter of withdrawal from Needmor and Unitarian Universalist Service Committee is forthcoming

In light of the urgency of the global climate crisis and the importance of the United States developing forward looking policy and regulations we did want to make some additional comments about the issues raised in the letter

The first is a process question The filing letter from Needmor as well as emails from myself stated quite clearly that we sought di~logue with the company about these issues In addition Walden Asset Management a long-time investor in Time Warner Cable and holder of 287000 shares for clients wrote a Jetter in September dealing with GHG and renewable goals as well as public policy advocacy on climate emphasizing investor concern about climate change

We are perplexed to understand why the company is responsive to shareowners on some issues while on other issues there is relative silence from management How can a group of investors get managements ~ttention and initiate dialogue on new climate related issues that are so important to a growing number of investors That is a specific communications issue we wish to raise

As the New York Times story today highlights the climate change issue is critically important to Gornpanies and investors alike

A Division of Boston Trust amp Investment Management Company One Beacon Street Boston Massachusetts 02108 6177267250 Fax 6172272690

We urge Time Warner Cable to embrace the spirit of the points in the shareholder resolution and carefully study Time Warner Cables involvement in the climate public policy debate

Asking a company to provide updated information to their investors on a key public policy issue is not an attempt to micromanage it is an attempt to be better informed

Thank you for this opportunity to put these concerns on the record We sincerely seek a meaningful dialogue with the company on these issues and will continue to seek ways to stimulate the management to respond

z~uTimothy Smith Senior Vice President Director of ESG Shareowner Engagement

Cc Mr Glenn Britt CEO Time Warner Cable Securities and Exchange Commission Corporate Finance Division Tom Robey Time Warner Cable Resolution Co-Filers- Needmor Fund Unitarian Universalist Service Committee

1

Time Warner Cable

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January 102014

Office of Chief Counsel Division of Corporation Finance Securities and Exchange Commission 100 F Street NE Washington DC 20549

Re Time Warner Cable Inc - Shareholder Proposal of the Unitarian Universalist Service Committee and The Needmor Fund


I am writing on behalf of Time Warner Cable Inc (the Company) to notify the staff of the Division of Corporation Finance (the S taff) of the US Securities and Exchange Commission (the Commission) of the Companys intention to exclude a shareholder proposal and related statement in support from the Companys materials for its 2014 Annual Meeting of Stockholders (the 20 I 4 Proxy Materials) The Company received letters from the Unitarian Universalist Service Committee and The Needmor Fund (the Proponents) jointly submitting the proposal (the Proposal) copies of which are attached as Exhibit A

In accordance with Rule 14a-8 under the Securities Exchange Act of 1934 as amended (the Exchange Act) we hereby respectfully request that the Staff confirm that no enforcement action will be recommended to the Commission against the Company if the Proposal is omitted from the 20 14 Proxy Materials As required by Exchange Act Rule 14a-8U) we have submitted this letter and its attachments not less than 80 days before the Company files its definitive 2014 Proxy Materials with the Commission A copy of this letter and its attachments is being sent concurrently to the Proponents in accordance with that Rule informing them of the Companys intention to omit the Proposal from the 2014 Proxy Materials The Company currently intends to begin di stribution of its definitive 2014 Proxy Materials on or around Apri l I 2014

Exchange Act Rule 14a-8(k) and Section E of Staff Legal Bull etin No 140 (Nov 7 2008) provide that shareholder proponents are required to end companies a copy of any correspondence that the shareholder proponent elects to s ubmit to the Commission or the Staff Accordingly we are taking this opportunity to remind the Proponents that if the Proponents either individually or jointly submit correspondence to the Commission or the Staff with respect to the Proposal a copy of that correspondence should concurrently be furnished to the undersigned

60 Columhus C~rcle

New York NY lOOn

Office ofChief Counsel Division of Corporation Finance Securities and Exchange Commission p 2

I The Proposal

The resolution contained in the Proposal states

Resolved Shareholders request that the Board of Directors initiate a review and assessment of organizations in which Time Warner Cable is a member or otherwise supports fmancially for involvement in lobbying on legislation at state or local levels A summary report of this review should be reviewed by the Board Governance Committee and provided to shareholders

We hereby respectfully request that the Staff confirm that no enforcement action will be recommended to the Commission against the Company if the Proposal is omitted from the 2014 Proxy Materials for the following reasons (i) pursuant to Exchange Act Rule 14ashy8(i)ll) (Rule 14a-8(i)(ll)) because it substantially duplicates another proposal previously submitted to the Company that the Company intends to include in its 2014 Proxy Materials and (ii) pursuant to Exchange Act Rule 14a-8(i)(7) (Rule 14a-8(i)(7)) because it relates to the ordinary business operations of the Company

ll The Proposal may be omitted based on Rule 14a-8(i)(ll) as it substantially duplicates a previously received proposal that the Company intends to include in its 2014 Proxy Materials

Rule 14a-8(i)ll) provides that a shareholder proposal may be excluded if it substantially duplicates another proposal previously submitted to the company by another proponent that will be included in the companys proxy materials for the same meeting The Commission has stated that the purpose of [Rule 14a-8(i)( 11)] is to eliminate the possibility of shareholders having to consider two or more substantially identical proposals submitted to an issuer by proponents acting independently of each other Exchange Act Release No 34-12999 (Nov 22 1976) (the 1976 Release) When two substantially duplicative proposals are received by a company the Staff has indicated that the company may exclude the later proposal assuming the company includes the first of the proposals in its proxy materials See Great Lakes Chemical Corp (avail Mar 2 1998) see also Pacific Gas amp Electric Co (avail Jan 6 1994)

On August 6 2013 the Company received by courier letters dated August 2 2013 from the Proponents jointly submitting the Proposal On August 1 2013 the Company had previously received by facsimile a shareholder proposal dated July 30 2013 from Walden Asset Management (the Prior Proposal a copy of which is attached as Exhibit B) containing the following resolution 1

Resolved the shareholders of Time Warner Cable request the Board authorize the preparation of a report updated annually and disclosing

1 Subsequently additional proponents joined in supporting the Prior Proposal

Office of Chief Counsel Division of Corporation Finance Securities and Exchange Commission p 3

1 Company policy and procedures governing lobbying both direct and indirect and grassroots lobbying communications

2 Payments by Time Warner Cable used for (a) direct or indirect lobbying or (b) grassroots lobbying communications in each case including the amount of the payment and the recipient

3 Time Warner Cables membership in and payments to any tax-exempt organization that writes and endorses model legislation

4 Description of the decision making process and oversight by management and the Board for making payments described in section 2 above

For purposes of this proposal a grassroots lobbying communication is a communication directed to the general public that (a) refers to specific legislation or regulation (b) reflects a view on the legislation or regulation and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation Indirect lobbying is lobbying engaged in by a trade association or other organization ofwhich Time Warner Cable is a member

Both direct and indirect lobbying and grassroots lobbying communications include efforts at the local state and federal levels

The report shall be presented to the Audit Committee or other relevant Board oversight committees and posted on the companys website

It is well settled that proposals need not be identical in order to be excludable under Rule 14a-8(i)(11 ) The standard that the Staff traditionally has applied for determining whether proposals are substantially duplicative is whether the proposals present the same principal thrust or principal focus Pacific Gas amp Electric Co (avail Feb 1 1993) If they do so the second proposal may be excluded as substantially duplicative of the frrst proposal despite differences in the terms or breadth of the proposals and even if the proposals request different actions Applying this standard the Staff has consistently found for example proposals concerning lobbying and proposals concerning the broader realm of political contributions to be duplicative despite proponents arguments that the two corporate activities were distinguishable See eg WeiPoint Inc (avail Feb 20 2013) JPMorgan Chase amp Co (avail Feb 24 2012) ATampT Inc (recon avail Mar 1 2012) and Occidental Petroleum Corp (avail Feb 25 2011) Similarly the Staff has concurred that a variety of proposals addressing lobbying are substantially duplicative for purposes of Rule 14a-8(i)(11) even where the terms and breadth of the two proposals have been somewhat different See eg Johnson amp Johnson (avail Feb 23 2012) Goldman Sachs Group Inc (avail Mar 14 2012)

The principal thrust and focus of both the Proposal and the Prior Proposal is the same specifically a review of and report on the Companys lobbying activities and policies


governing these activities including the organizations of which it is a member and recipients of its financial support In particular

bull Both proposals request a review of the Companys lobbying activities

bull Both proposals require the report be reviewed by a Board committee and provided to shareholders

bull Both proposals address concerns regarding indirect lobbying efforts by the Company

bull Both proposals seek greater transparency regarding the policies and procedures by which the Company determines to support such efforts and oversight and compliance with such policies and procedures

bull Both proposals allude to the potential reputational risk to the Company posed by its lobbying activities and refer specifically to the American Legislative Exchange Council (ALEC) as an example of a lobbying organization of which the Company is a member which takes positions allegedly counter to the Companys policies

The shared thrust and focus of the Proposal and Prior Proposal is further evidenced by the similarities and argumentation included in their recitals and supporting statements They each focus on investor concern and skepticism about involvement in lobbying the need for related transparency and the proponents negative views about the Companys involvement with ALEC

Not only are the proposals focused on the same outcome the slightly more specific focus of the Proposal is subsumed in the Prior Proposal Logically the Staff has found shareholder proposals to have the same principal thrust and thus to be substantially duplicative and excludable under Rule 14a-8(i)(ll ) where one proposal is subsumed by the other See eg General Electric Company (avail Jan 23 2013) (concurring with the exclusion under Rule 14ashy8(i)(ll) of a proposal to adopt a policy that the company no longer pay dividends or dividend equivalent payments to senior executives for unvested shares as substantially duplicative of an earlier proposal that the company cease all Executive Stock Option Programs and Bonus Programs) and Bank ofAmerica Corp (avail Feb 24 2009) (concurring with the exclusion under Rule 14a-8(i)(ll) of a proposal requesting a policy requiring senior executives to hold at least 75 of shares acquired through equity compensations programs until two years after their termination or retirement as substantially duplicative of an earlier proposal in which a similar policy was one of the many requests made) In each case the action requested by the later proposal was already covered by the action requested in the earlier proposal rendering the later proposal duplicative

Office of Chief Counsel Division of Corporation Finance Secwities and Exchange Commission p 5

The Proposal is clearly subsumed by the Prior Proposal

bull The Proposal focuses on lobbying regarding legislation at the state or local level the Prior Proposal includes in its scope lobbying regarding legislation on the local state and federal levels

bull The Proposal requests a review and assessment of lobbying organizations with which the Company is involved and the rationale for the Companys support of them the Prior Proposal requests information regarding the identity of organizations of which the Company is a member or to which the Company contributes money as well as a description of the Companys decision making process and the policies and procedures governing its involvement with such entities

bull The Proposal asks for a single report the Prior Proposal asks for an annually updated report

It would be difficult if not impossible to implement the Prior Proposal and meet the concerns expressed therein without addressing the concerns raised in and taking the actions requested by the Proposal

Because of the duplication including both proposals in the Companys 2014 Proxy Materials would require the Companys shareholders to consider substantially the same matters and would create the risk of confusing them Shareholders might incorrectly assume that the proposals were substantively different and the requested reports directed toward dissimilar issues This result would be in direct contradiction of the purpose of Rule 14a-8(i)(11) described above Accordingly the Company believes that the Proposal may be excluded from the 2014 Proxy Materials as substantially duplicative of the Prior Proposal

III The Proposal may be excluded based on Rule 14a-8(i)(7) because it relates to the Companys ordinary business operations

The Commission has consistently taken the position that a shareholder proposal may be omitted from a proxy statement under Rule 14a-8(i)(7) if it relates to the companys ordinary business operations In Exchange Act Release No 34-40018 (May 21 1998) (the 1998 Release) the Commission noted that the term ordinary business is rooted in the corporate law concept providing management with flexibility in directing certain core matters involving the companys business and operations and refers to matters that are not necessarily ordinary in the common meaning of the word The Commission further explained that the general policy underlying the Rule 14a-8(i)(7) exclusion is to confine the resolution of ordinary business problems to management and the board of directors since it is impracticable for shareholders to decide how to solve such problems at an annual shareholders meeting


The Commissions guidance for the analysis of ordinary business operations focuses on two key considerations See 1998 Release First whether the tasks addressed by the shareholder proposal are so fundamental to managements ability to run a company on a day-toshyday basis that they could not as a practical matter be subject to direct shareholder oversight Second the degree to which the proposal seeks to micro-manage the company by probing too deeply into matters of a complex nature upon which shareholders as a group would not be in a position to make an informed judgment 1998 Release

The Proposal may be omitted under Rule 14a-8(i)(7) as related to the Companys ordinary business operations because it attempts to micro-manage the Companys choice of lobbying activities organizations and contributions The Company devotes significant time and resources to participating in the legislative and regulatory process including taking positions on legislative policies that management believes are in line with the best interests of the Company This process involves a review and evaluation of numerous factors including the likelihood that lobbying efforts will be successful and the anticipated effect of specific regulations on the Companys financial position and shareholder value Likewise decisions as to how best to implement the Companys lobbying policies and accomplish its regulatory objectives including what organizations to support in light of the Companys legislative and regulatory goals involve complex decisions implicating the impact of the proposed legislation or regulation on the Companys business the use of corporate resources and the interaction of such efforts with other lobbying and public policy communications by the Company Shareholders are not well positioned to make such judgments and as a result such matters are more appropriately addressed by management and the Board

The Staff has consistently supported the position that a companys selection of organizations to which it contributes involves ordinary business decisions that are best left to the discretion of the companys management Accordingly proposals requesting a company to take action with respect to contributions to specific types of organizations relate to a companys ordinary business operations and may be excluded from proxy materials pursuant to Rule 14ashy8(i)(7) See eg Pfizer Inc (PETA (avail Feb 12 2007) (permitting exclusion of a proposal seeking a report on the justification for contributing to the advancement of animal-based testing) Moreover there is considerable Staff precedent establishing that the facts circumstances and evidence surrounding a shareholder proposal including preambles and supporting statements can be considered to determine whether a proposal is focused on contributions to specific types of activities or organizations While the resolution in the Proposal may be neutral on its face the Proposals preamble references ALEC and the Companys membership in ALEC in five out of six paragraphs (We note that the Prior Proposal also referenced ALEC but only in a single paragraph of its supporting statement as one of two examples) One of the paragraphs specifically cites other corporations that have disassociated themselves from ALEC leaving little doubt about the true message in the Proponents Proposa12 Accordingly the resolution when

2 On January 6 2014 Walden Asset Management issued a release (a copy ofwhich is attached as Exhibit C) indicating that a number of its clients and other parties including the Proponents have submitted shareholder proposals similar or identical to the Proposal to a number of companies The text of the release clearly indicates that

Office of Chief Counsel Division ofCorporation Finance Secmities and Exchange Commission p 7

read together with its preamble and supporting statement is comparable to a series of letters in which the Staff has concurred with the exclusion of shareholder proposals regarding general charitable giving where the supporting statements indicate that the proposal in fact would serve as a shareholder referendum on donations to a particular charity or type of charity For example in Johnson amp Johnson (avail Feb 12 2007) a proposal requesting that the board of directors implement a policy listing all charitable contributions on the Companys websites was excludable notwithstanding its facially neutral language The Staff concurred that the proposal could be excluded under Rule 14a-8(i)(7) because the supporting statement and two of the seven Whereas clauses preceding the resolution centered around contributions to Planned Parenthood and organizations that support abortion and same-sex marriage See also Home Depot Inc (avail Mar 18 2011) (permitting exclusion of a proposal requesting a listing of recipients of charitable contributions or merchandise vouchers of $5000 or more because the proposal though facially neutral related to specific types of organizations ie groups supporting the gay lesbian bi-sexual and transgender community) and Bank ofAmerica Corp (avail Jan 24 2003) (permitting exclusion of a proposal to cease making charitable contributions because the preamble and supporting statement frequently referenced abortion and religious beliefs)

The Company believes that the Proponents objective is to target a specific lobbying organization in an attempt to substitute shareholders judgment for the judgment of management and the Board on an ordinary business decision regarding the selection of lobbying organizations that serve the Companys goals Accordingly the Proposal falls within the scope of the no-action letters previously issued by the Staff concur with the exclusion of proposals pursuant to Rule 14a-8(i)(7)

For the foregoing reasons the Company believes it may properly exclude the

Proposal from the 2014 Proxy Materials under Exchange Act Rules 14a-8(i)(l1) and 14a-8(i)(7) Accordingly the Company respectfully requests that the Staff concm that it would not recommend enforcement action to the Commission if the Company omits the Proposal from its 2014 Proxy Materials If the Staff does not concm with the Companys position we would appreciate an opportunity to confer with the Staff concerning this matter prior to the issuance of a response The Proponents are requested to copy the undersigned on any response it may choose to make to the Staff

the purpose of these proposals is to challenge companies support ofone specific organization- namely ALEC As noted previously Walden Asset Management is the proponent of the Prior Proposal


If you have any questions or need any further information please contact the undersigned by telephone at 212-364-8519 or by email at susanwaxenbergtwcablecom

Very truly yours

swCLt A 0~4 Susan A Waxenberg Vice President amp Chief Counsel Securities

cc Constance Kane The Unitarian Universalist Service Committee Daniel Stranahan the Needmor Fund Timothy Smith Walden Asset Management Mary E Alcock Cleary Gottlieb Steen amp Hamilton LLP

Exhibit A Letters from the Proponents received by the Company on

August 6 2013

~~ uusc

August 2 2013 RECEIVED Mr Marc Lawrence-Appelbaum Corporate Secretary Time Warner Cable Inc AUG - 6 2013 60 Columbus Circle 1 ylh floor New York NY 10023 Time Wamer Cable

Law Department


For over 70 years UUSC has advanced human rights and social justice in the United States and internationally In order to pursue these goals we partner with a number of grassroots organizations around the world Representatives of these partners tell us of the great need for global corporations to adopt and implement company-wide policies and practices which protect human rights and the just treatment of employees and which also sustain the environment

The Unitarian Universalist Service Committee (UUSC) is the beneficial owner of 800 shares of Time Warner Cable stock We have owned over $2000 worth for more than a year and it is our intent to hold greater than $2000 in market value through the next annual meeting of T ime Warner Cable Our custodian will gladly provide certification of our ownership

This resolution is submitted for consideration and action by the stockholders at the next annual meeting and for inclusion in the 2014 proxy statement under Ru le 14 a-8 of the general rules and regulations of the Securities and Exchange Act of 1934 We are co-filing this resolution with Needmor Fund as the primary filer and deputize them to withdraw the resolution for us We will be represented in person or by proxy at the annual meeting

Sincerely ~ ~

qi~~e a~ lftA 1

Chief Operations Officer _ 7 Enclosure Resolution

Cc Timothy Smith - Walden Asset Management

UNITARIAN UNIVERSALIST SERVICE COMMITTEE 689 Massachusetts Avenue Cambridge MA 02139-3302617-868-6600 f ax 617-868-7102

www uuscorg

Boston Trust amp Investment Management Company

August 2 2013

To Whom It May Concern

Boston Trust amp Investment Management Company a state chartered bank under the Commonwealth of Massachusetts and insured by the FDIC manages assets and acts as custodian for the Unitarian Universalist Service Committee through its Walden Asset Management division

We are writing to verify that our client Unitarian Universalist Service Committee currently owns 800 shares of Time Warner Cable Inc (Cusip 88732J207) These shares are held in the name of Cede amp Co under the custodianship of Boston Trust and reported as such to the SEC via the quarterly filing by Boston Trust of Form 13F

We confirm that Unitarian Universalist Service Committee has continuously owned and has beneficial ownership of at least $2 000 in market value of the voting securities of Time Warner Cable Inc and that such beneficial ownership has existed for one or more years in accordance with rule 14a-8(a)(1) of the Securities Exchange Act of 1934 Additional documentation confirming ownership from our sub-custodians who are DTC participants will be provided

Further it is our intent to hold at least $2000 in market value in the Unitarian Universalist Service Committee account through the next annual meeting

Should you require further information please contact Timothy Sm ith at 617-726-7155 or tsmithbostontrustcom directly

__j__QJL Timothy Smith Senior Vice President

O N ll eacl~ Sueet Boston lvlcssachUiet5 021 OB 6 17 726 7250 fax 617 177 7 690

REVIEW LOBBYING AT STATE LEVEL

Whereas Investors are increasingly concerned about how companies are lobbying at the federal state and local levels including indirect lobbying through trade associations and tax-exempt organizations A high level of transparency helps ensure that lobbying activities are consistent with stated corporate policies and values thereby reducing reputational and business risk that have the potential to alienate consumers investors and other stakeholders

The tax-exempt American Legislative Exchange Council (ALEC) has come under unique scrutiny due to its controversial and partisan public policy positions and the lobbying enabled by the organization through model legislation it provides and promotes ALEC has been associated with contentious anti-immigration voter identification and 11Stand Your Ground legislation More recently ALEC Initiatives have focused on opposition to climate change policies and efforts to weaken state renewable energy standards with the Heartland Institute

Time Warner Cable is a member of ALEC and funds its work We believe this partnership may bring significant reputational and business risk to the company

For example legislation inspired by ALECs modeiEiectricity Freedom Act calling for the repeal of state-level Renewable Portfolio Standards is being presented to a number of state legislatures In contrast Time Warner Cable is a leader in its commitment to address the environment and climate change

As of July 2013 50 corporations have ended ties with ALEC Major corporations across a range of industries have disassociated such as Brown-Forman Coca-Cola John Deere Dell Computers General Electric General Motors Johnson amp Johnson McDonalds Medtronic PepsiCo Procter amp Gamble Unilever and Wai-Mart In suspending its membership in ALEC in 2012 Wai-Marts VP of Public Affairs remarked We feel that the divide between these activities and our purpose as a business has become too wide

Yet Time Warner Cable has decided to stay as an ALEC member and funder and refuses to speak out on ALEC positions that violate Time Warner Cables policies and values

Resolved Shareholders request that the Board of Directors initiate a review and assessment of organizations in which Time Warner Cable is a member or otherwise supports financially for involvement In lobbying on legislation at state or local levels A summary report of this review should be reviewed by the Board Governance Committee and provided to shareholders

SUPPORTING STATEMENT

We propose the review should

1 Examine the philosophy major objectives and actions taken by the organization supported

2 Assess the consistency between our companys stated policies principles and Code of Conduct with those of the organization supported

3 Determine if the relationship carries reputational or business risk that could have a negative impact on the company its shareholders or other stakeholders

4 Evaluate managements rationale for its direct involvement in or financial support of the organization to determine if the support is in the long-term best interests of the company and its stakeholders

5 Assess current and potential internal oversight and controls governing the use of corporate assets for political purposes

THE NEEDMOR FUND

RECEIVED

August 2 2013

AUG - 6 2013 Mr Marc Lawrance-Appelbaum Corporate Secretary

Time Warner Cable Time Warner Cable Inc Law Department 60 Columbus Circle 1 yh floor New York NY 10023

Dear Mr Lawrance-Appelbaum

The Needmor Fund holds 1066 shares of Time Warner Cable stock We strongly believe as were sure you do that good governance and corporate responsibility is essential for building shareholder value

We are filing the enclosed shareholder proposal as the primary filer for inclusion in the 2014 proxy statement in accordance with Rule 14a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934 We are the beneficial owner as defined in Rule 13d-3 of the Securities Exchange Act of 1934 of the above mentioned number of Time Warner Cable shares and will continue to hold at least $2000 worth of Time Warner Cable stock through the next annual meeting We will be pleased to provide proof of ownership upon request

Please copy correspondence both to myself and to Timothy Smith at Walden Asset Management at tsmithbostontrustcom phone 617-726-7155

We look forward to your response and dialogue in this issue

)Jta41dcw~Ajh ~mel Stranat~~ middot Chair- Finance Committee

Encl Resolution Text

CC Timothy Smith Walden Asset Management One Beacon St Boston MA 02108

The Ncedmo r Fund co Daniel Stranahan

2123 West Web ster Avenue Chicago IL 60647



The tax-exempt American legislative Exchange Council (ALEC) has come under unique scrutiny due to its controversial and partisan public policy positions and the lobbying enabled by the organization through model legislation it provides and promotes ALEC has been associated with contentious anti-immigration voter identification and Stand Your Ground legislation More recently ALEC initiatives have focused on opposition to climate change policies and efforts to weaken state renewable energy standards with the Heartland Institute



As of July 2013 50 corporations have ended ties with ALEC Major corporations across a range of industries have disassociated such as Brown-Forman Coca-Cola John Deere Dell Computers General Electric General Motors Johnson ampJohnson McDonalds Medtronic PepsiCo Procter ampGamble Unilever and Wai-Mart In suspending its membership in ALEC in 2012 Wai-Marts VP of Public Affairs remarked We feel that the divide between these activities and our purpose as a business has become too wide

Vet Time Warner Cable has decided to stay as an ALEC member and funder and refuses to speak out on ALEC positions that violate Time Warner Cables policies and values

Resolved Shareholders request that the Board of Directors initiate a review and assessment of organizations in which Time Warner Cable is a member or otherwise supports financially for involvement in lobbying on legislation at state or local levels A summary report of this review should be reviewed by the Board Governance Committee and provided to shareholders








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ExhibitB Letter from Walden Asset Management

received by the Company on August 1 2013

July 30 2013

Mr Marc Lawrance-Appelbaum Corporate Secretary Time Warner Cable Inc 60 Columbus Circle 1 th floor New York NY 10023


Walden Asset Management holds at least 285785 shares of Time Warner Cable on behalf of clients who ask us to integrate environmental social and governance analysis (ESG) into investment decisionshymaking Walden Asset Management a division of Boston Trust amp Investment Management Company is an investment manager with approximately $25 billion in assets under management We are pleased to be a long-term owner of Time Warner Cable stock

Walden Asset Management is filing this resolution once again with Time Warner Cable seeking a review of your lobbying disclosure policies and practices as we did last year We look forward to continuing a constructive dialogue on this important topic as we have on many other issues in the past

We are filing the enclosed shareholder proposal with for inclusion in the 2014 proxy statement in accordance with Rule 14a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934 We are the beneficial owner as defined in Rule 13d-3 of the Securities Exchange Act of 1934 of the above mentioned number of Time Warner Cable shares Walden Asset Management will act as the primary filer of the resolution

We have been a shareholder for more than one year holding over $2000 of Time Warner Cable shares and will continue to hold at least $2000 of Time Warner Cable stock through the next annual meeting Verification of our ownership position will be provided on request by our sub-custodian who is a DTC participant A representative of the filers will attend the stockholders meeting to move the resolution as required by SEC rules

Sincerely () h

(~ J-L)A Timothy Smith Senior Vice President Director of ESG Shareholder Engagement

Cc Tom Robey Time Warner Cable

282


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Date July 30 2013


State Street Bank and Trust Company (State Street) has acted as subshycustodian for Boston Trust amp Investment Management Company (Boston Trust) since October 24 2011 Walden Asset Management is the investment division of Boston Trust dealing with environmental social and governance matter

In connection with a shareholder proposal submitted by Boston Trust on July 30 2013 we are writing to confirm that Boston Trust has had beneficial ownership of a least $2000 in market value of the voting securities of Time Warner Cable Inc (CusipBB732J207) since October 24 2011

State Street serves as the sub-custodian for Boston Trust and Investment Management Company State Street is a DTC participant

In witness hereof the individual signing below confirms to best of her knowledge that the above statements are true and accurate

Sincerely

Melissa A Dewey Assistant Vice President

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Lobbying Disclosure

Whereas businesses like individuals have a recognized legal right to express opinions to legislators and regulators on public policy matters

We believe it is important that Time Warner Cables lobbying positions and processes to influence public policy are transparent Public opinion is skeptical of corporate influence on Congress and public policy and controversial lobbying activity may pose risks to our companys reputation We encourage full disclosure of Time Warner Cables policies procedures and oversight mechanisms

Time Warner Cable spent approximately $23 million in 2010 2011 and 2012 on federal lobbying according to Senate reports But this figure may not include grassroots lobbying to influence legislation by mobilizing public support or opposition Also not all states require disclosure of lobbying expenditures The reports also do not include contributions to tax-exempt organizations which write and endorse model legislation






For purposes of this proposal a grassroots lobbying communication is a communication directed to the general public that (a) refers to specific legislation or regulation (b) reflects a view on the legislation or regulation and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation Indirect lobbying is lobbying engaged in by a trade association or other organization of which Time Warner Cable is a member



Supporting Statement

We encourage transparency as corporate funds influence legislation and regulation directly and indirectly We commend Time Warner Cable for updating the disclosure on its website but it stills does not disclose lobbying through trade associations maintaining secrecy as it directs funds or lobbies through these associations For example the US Chamber of Commerce spent over $1 billion in lobbying since 1998 yet any Time Warner Cable funds spent through trade associations are secret

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For example Time Warner Cable is a member of the American Legislative Exchange Council (ALEC) which campaigns vigorously against measures to stop climate change Most recently ALEC is involved in a campaign challenging renewable energy legislation and regulation at the State level In contrast website Time Warner Cables website publicly affirms its commitment to protecting the environment

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ExhibitC Walden Asset Management Release dated January 6 2014

Investors Raise New Set of Issues with Companies on Public Policy and Climate

January 6 2014- Investors have engaged co mpanies for over 20 yea rs on climate change but this yea r there is a new set of sharehold er resolutions challenging companies to eva lu ate their public policy advocacy specifically related to climate change

These resolutions are part of a larger investor cl im ate initiative Raising the Bar with com panies in response to the expanding and alarming scientific evidence of changing cl im ate and its signif icant negative environmental and econom ic impacts accompanied by grow ing risk to companies and investors alike

Pressing Energy Companies on their Public Policy Positions on Climate

One new cat egory of resolution s presses fossil fuel companies and major energy producers to do a Board leve l review of t heir public policy position s and lobbying activit ies related to energy policy and climate change

There is a wides pread public perception t hat energy companies have regu larl y opposed new legislation or regu lation add ressing climate change The re al picture may be mo re comp licated than this perception but sha rehold er proponents argue it is time for companies to evaluate their pub lic policy positions and lobbying on cl imate and fully disclose the resu lts to investors

Seven compa ni es have received such a resol ution American Electric Power Chevron ConocoPhillips Devon Energy Dominion Resources and Exxon Mobil

The resoluti on add re sses both direct public poli cy advocacy by the compa ni es as well as advocacy throu gh third-party trade associations such as the US Chamb er of Comme rce (Chambe r) American Petroleum Institute and Nati onal Association of Manufa cturers (NAM )

The Chamber and NAM have aggressively campa igned against climate change legislation and regulation going so far as to sue (unsuccessfu lly) the EPA in an attempt to block it from exercising authority over greenhouse gas emissions

The Chambe r has become by far t he most muscular business lobby group in Washi ngton (The Chamber of Secrets The Economist April 21 2012 and since 1998 has spent approximately $1 billi on on lobbying Thus m ajor businesses w ho are members of the Chamber or sit on its Board bear significant responsibility f o r the Chambers actions on climate

A Division of Boston Trust amp Investme nt M anagem ent Company

One Beacon Street Boston M assachusetts 02108 (617) 726-7250 fax (617) 227-2690

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The resolution (see enclosed examp le to Chevron) ca lls for an ana lysis of a companys public policy posit ions and whether a companys lobbying and expenditures directly o r indirectly are blocking or advancing action to address climate change

Resolution filers includ e clients of Wa lden Asset Management PAX World Funds First Affir mative Financial Network Zevin Asset Management The Christopher Reynolds Fo und ation Russell Family Found ation Need mor Fund religiou s organizations including the Capuchin Provin ce of St Jose ph Everence Financial Services and the Unitarian Unive rsa list Service Association

Review Lobbying at Federal State and Local Levels including ALEC

A second category of resolut ion ca lls for compa nies to review lobbying including at the st ate level and was f iled with companies that provided financial support to the Ame ri can Legislative Exchange Coun cil (ALEC)

ALEC has been actively promoting a w ide range of public policies by creating model legislat ion for submission to state legisl atu res Because of its active role in the public policy process ALECs taxshyexempt status has been officially challenged at the IRS

Of particular concern for environmentalists is ALECs active campaign against sta t e regulation s and legislation suppo rting renewable energy In this campa ign ALEC has partnered with the Heartland Institute a climate change denying organizatio n but to date they have had a zero batting average at state legislatures

ALECs broad -based partisan agenda and cont roversia l policy positions have prompted a review of this re lationship by nu merous compan ies To date over 50 companies have severed ties to ALEC

Companies receiving this resolution include Dominion Resources Microsoft Occidenta l Petroleum Pfizer Time Warner Cable and United Parcel Service

Sponsors of this resolution includ e the State of Connecticut Retirement Plan s and Tru st Funds New York St at e Common Retirement Fund foundation s including The Christopher Reynolds Foundation and Needmor Fund re ligious organizations including the Unitarian Universa list Service Assoc iat ion United Church Funds and Sist ers of Charity of the Incarn ate Word Texas sust ainable investm ent firms such as Th e Susta in ability Group (Lorin g Wolcott) Zevin Asset M anagement and cli ents of Walden Asset Management

The re solution to Microsoft was withdrawn in light of the companys leade rship position supporting renewable energy at the state leve l and its open opposit ion to ALECs lobbying campaign against renewables

Several com panies have chall enged this resolution at the Securities and Exchange Com mission (SEC) including Dominion Resources and United Parcel Service

Othe rs have agreed to allow a vote at the 2014 stockholder meeting (see enclosed example to Pfizer)

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Sample Resolution Chevron - Review Public Policy Advocacy on Energy Policy and Climate Change

Whereas The Intergovernmental Panel on Climate Change (IPCC) the worlds leading scientific authority on climate change in their 2013 report confirm warming of the climate is unequivocal and human influence is the dominant cause Recent extreme weather events have caused significant loss of life and billions of dollars of damage Many investors are deeply concerned about existing and future effects of climate change on society and business

The IPCC estimates that a 50 reduction in greenhouse gas emissions globally is needed by 2050 (from 1990 levels) to stabilize global temperatures entailing a US target reduction of 80

Urgent action is needed to achieve the required emissions reduction We believe the US Congress Administration as well as States and cities must enact and enforce strong legislation and regulations to mitigate and adapt to climate change reduce our use of fossil fuels and move us to a renewable energy future

Accordingly we believe companies in the energy sector should review and update their public policy positions related to climate change

The public perception is that business often opposes laws and regulations addressing climate change or renewable energy For example in 2009 when Congress debated comprehensive climate change legislation oil gas and electric utilities spent more than $300 million on lobbying (Opensecretsorg)

Consequently company political spending and lobbying on energy policy including through third parties are increasingly scrutinized For example investors question company public policy advocacy through the US Chamber of Commerce which often obstructs progress on climate-related legislation

Investors have asked hundreds of companies to disclose their political spending and lobbying policies and over 125 SampP 500 companies now make such disclosures

Over 500 forward looking businesses such as General Motors Microsoft Nike and Unilever signed the Climate Declaration that supports the need for legislation and states Tackling Climate Change is one of Americas greatest economic opportunities of the 21st Century

Resolved Shareholders request that independent Board members commission a comprehensive review of Chevrons positions oversight and processes related to public policy advocacy on energy policy and climate change This would include an analysis of political advocacy and lobbying activities including indirect support through trade associations think tanks and other nonprofit organizations Shareholders also request the company to prepare (at reasonable cost and omitting confidential information) and make available by September 2014 a report describing the completed review

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We recommend that this review include

bull Whether our current company positions on climate legislation and regulation are consistent with the reductions deemed necessary by the IPCC

bull Board oversight of our companys public policy advocacy on climate bull Direct and indirect expenditures (including dues and special payments) for issue ads designed to

influence elections ballot initiatives or legislation related to climate change bull Engagements with climate scientists and other stakeholders involved in climate policy

discussions bull Proposed actions to be taken as a result of the review

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Sample Resolution Pfizer- Review Lobbying at Federal State and Local Levels

Whereas Investors are increasingly concerned about how companies lobby at the federal state and local levels including indirect lobbying through trade associations and tax-exempt organizations A high level of transparency helps ensure lobbying activities are consistent with stated corporate policies and values thereby reducing reputational and business risk that potentially could alienate consumers investors and other stakeholders

The tax-exempt American Legislative Exchange Council (ALEC) has come under unique scrutiny due to its controversial and partisan public policy positions and the lobbying enabled by the organization through model legislation it provides and promotes ALEC has been associated with contentious antishyimmigration voter identification and Stand Your Ground legislation More recently ALEC initiatives have opposed climate change policies and efforts to weaken state renewable energy standards with the Heartland Institute

Pfizer is a member of ALEC and funds its work We believe this partnership may bring significant reputational and business risk to the company

For example legislation inspired by ALECs model Electricity Freedom Act calling for the repeal of state-level Renewable Portfolio Standards is being presented to a number of state legislatures In contrast Pfizer is a leader in its commitment to address the environment and climate change

As of July 2013 50 corporations have ended ties with ALEC Major corporations across a range of industries have disassociated such as Brown-Forman Coca-Cola John Deere Dell Computers General Electric General Motors Johnson amp Johnson McDonalds Medtronic PepsiCo Procter amp Gamble Sallie Mae Unilever and Wai-Mart In suspending its membership in ALEC in 2012 Wai-Marts VP of Public Affairs remarked We feel that the divide between these activities and our purpose as a business has become too wide

Yet Pfizer has decided to continue as an ALEC supporter and does not speak out on ALEC positions that violate our companys policies and values

Resolved Shareholders request that the Board of Directors initiate a review and assessment of organizations in which Pfizer is a member or otherwise supports financially for involvement in lobbying on legislation at federal state or local levels A summary report of this review prepared at reasonable cost and omitting proprietary information should be reviewed by the Board Governance Committee and provided to shareholders

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1 Examine the philosophy major objectives and actions taken by the organization supported 2 Assess the consistency between our companys stated policies principles and Code of Conduct

with those of the organization supported 3 Determine if the relationship carries reputational or business risk that could have a negative

impact on the company its shareholders or other stakeholders 4 Evaluate managements rationale for its direct involvement in or financial support of the

organization to determine if the support is in the long-term best interests of the company and its stakeholders


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Time Warner Cable

BY OVERNIGHT COURIER

Office of Chief Counsel Division of Corporation Finance Securities and Exchange Commission 100 F Street N E Washington DC 20549

January 222014


Re Time Warner Cable Inc- Shareholder Proposal of the Unitarian Universalist Service Committee and The Needmor Fund-shyWithdrawal of Request

In a letter dated January 10 2014 on behalf ofTime Warner Cable Inc (the Company) I requested that the Staff of the Division of Corporation Finance concur that the Company could properly exclude from its proxy statement and proxy to be filed and distributed in connection with its 2014 annual meeting ofstockholders (collectively the 2014 Proxy Materials) a proposal (the Proposal) and supporting statement submitted to the Company on August 6 2013 by the Unitarian Universalist Service Committee and The Needmor Fund as coshyfilers (the Proponents~)

Attached as Exhibit A and Exhibit B respectively is a letter dated January 17 2014 from each Proponent to the Company stating that each Proponent voluntarily withdraws the Proposal In reliance on this letter we hereby withdraw the January 102014 no-action request relating to the Companys ability to exclude the Proposal from its 2014 Proxy Materials pursuant to Rule 14a-8 under the Securities Exchange Act of 1934

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Please do not hesitate to call me at (212) 364-8519 or by fax at (704) 973-6245 if I may be of further assistance in this matter

Sincerely

fwcuL A lJ~~ Susan A Waxenberg [I Vice President amp Chief Counsel Securities

Enclosures

60 Colun1bus Circle

New York NY 10023


Exhibit A


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January 17 2014








ExhibitB


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- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy


August 6 2013

~~ uusc


Law Department





Sincerely ~ ~

qi~~e a~ lftA 1




www uuscorg


August 2 2013
























THE NEEDMOR FUND

RECEIVED

August 2 2013




























~ - ~ I I

bull bull ~ I



July 30 2013







Sincerely () h



282



_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy

~~ uusc


Law Department





Sincerely ~ ~

qi~~e a~ lftA 1




www uuscorg


August 2 2013
























THE NEEDMOR FUND

RECEIVED

August 2 2013




























~ - ~ I I

bull bull ~ I



July 30 2013







Sincerely () h



282



_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy


August 2 2013
























THE NEEDMOR FUND

RECEIVED

August 2 2013




























~ - ~ I I

bull bull ~ I



July 30 2013







Sincerely () h



282



_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy
















THE NEEDMOR FUND

RECEIVED

August 2 2013




























~ - ~ I I

bull bull ~ I



July 30 2013







Sincerely () h



282



_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy
















~ - ~ I I

bull bull ~ I



July 30 2013







Sincerely () h



282



_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy



July 30 2013







Sincerely () h



282



_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy


_-middot

middotI

bull f

bull

bull

middot

- middotmiddot-~

middot~

- ~

~

middot-

~ _

bull i

~ ~ I - bull

~



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy



Date July 30 2013






Sincerely


Date ~z ~r~

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy

~

bull

i

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy

Lobbying Disclosure














-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


_ bullbull -~f

middotmiddot

~- I


~ _ f ( I


middot







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy

-

-middotmiddot

~ _ bull I

bull _ ~

~

middot

~ i

__-)

_

_ middot ~ ~

- ~ _ bull


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


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middotmiddot

~- I


~ _ f ( I


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- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy


middot It_














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


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~- I


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- ~

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middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy














- ~ ---middot

-middot ~

~

middotr --

bull middot

~- 1

J

middotmiddot













rmiddotmiddot

r



~











middot~ l

--shybull


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~- I


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middot

middotmiddot middot

middotbull

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~

bull t middotmiddot

-

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- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy













rmiddotmiddot

r



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--shybull


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middotmiddot middot

middotbull

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~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy











middot~ l

--shybull


_ bullbull -~f

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~- I


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middot

middotmiddot middot

middotbull

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~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy







- ~

bull









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy









middot

middotmiddot middot

middotbull

middot_

~

bull t middotmiddot

-

middotmiddot

- bullbull jmiddot








1middot

middotmiddott

~

~ ~


__

-shy








1middot

middotmiddott

~

~ ~


__

-shy

SECURITIES AND EXCHANGE COMMISSION - SEC.gov | HOME · 100 F Street, N.E. Washington, D.C. 20549 ....

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Transcript of SECURITIES AND EXCHANGE COMMISSION - SEC.gov | HOME · 100 F Street, N.E. Washington, D.C. 20549 ....